Early in 2007, it appeared as if the DOJ would potentially undertake an unprecedented prosecution of individual board members of Chiquita because the company had failed to stop illegal overseas payments in a timely fashion even after it had self-disclosed the conduct. For a number of years, Chiquita had been paying a paramilitary group protection money to ensure the smooth operation of its subsidiary in Columbia. In the end, at Malis’ discretion, DOJ showed reasonable restraint and declined to pursue charges against the individual board members. Why was this important? Because going down the path of prosecution would have jeopardized the increasingly accepted self-disclosure doctrine, resulting in potential rapid diminishment in the number of companies cooperating with DOJ.